HomeMy WebLinkAbout01-04780CHARLENE M. SHEARER and
MERVIN E. SHEARER, her husband,
Plaintiffs
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SHERATON VALLEY FORGE HOTEL,
RADISSON VALLEY FORGE HOTEL, and
GF MANAGEMENT,
Defendants
IN THE COURT OF COMMON PLEAS O~
CUMBERLAND COUNTY, PENNSYLVANIA
NO. CIVIL TERM -LAW
O1~ ~1~5'O c,~l~
PRAECH'E FOR ISSUANCE OF A WRIT OF SUMMONS
TO CURTIS R LONG, PROTHONOTARY:
Please issue a Writ of Summons against the defendants, Sheraton Valley Forge Hotel, Radhsson Valley
Forge Hotel and GF Management, and enter my appearance on behalf of the plaintiffs, Charlene M. Shearer and
Mervin E. Shearer. Please duect the Sheriff to serve the defendants as follows:
GF Management, A Limited Partnership
Sheraton Valley Forge Hotel
Radhsson Valley Forge Hotel
1160 First Avenue
King of Prussia, PA 19406
Respectfully submitted,
IRWIN, McKNIGHT &
Marcus A. cI{nigh Esq 're
60 West Pomfret Street, A 17013
Date: August 13, 2001 (717) 249-2353 -Supreme Court I.D. No: 25476
To: SHERATON VALLEY FORGE HOTEL, RADISSON VALLEY FORGE HOTEL, and
GF MANAGEMENT, A Limited Partnership
You aze hereby notified that Charlene M. Shearer and Mervin E. Shearer, plaintiffs, have commenced
an action against you which you are required to defend or a default judgment may be entered against you.
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PROTH OTARY
By: `~J~~~ ~ ~f
'/~/ 11 ~ DEPUTY' /
Date: i_, 2001
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SHERIFF'S RETURN - OUT OF COUNTY
CASE, NO: 2001-04780 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SHEARER CHARLENE ET AL
VS
SHERATON VALLEY FORGE HOTEL ET
R. Thomas Kline Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
to wit:
SHERATON VALLEY FORGE HOTEL
but was unable to locate Them in his bailiwick. He therefore
deputized the sheriff of MONTGOMERY County, Pennsylvania, to
serve the within WRIT OF SUMMONS
On August 28th 2001 this office was in receipt of the
attached return from MONTGOMERY
Sheriff's Costs: So answe
Docketing 18.00
Out of County 9.00 /
Surcharge 10.00 R. '~homas Kline
Dep Montgomery Co 65.00 Sheriff of Cumberland County
.00
102.00
08/28/2001
IRWIN MCKNIGHT & HUGHES
Sworn and subscribed to before me
this j,~~ day of
Gov/n A.D. ~ '"
~ Prothonotary] ~
.-
" ~ SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2001-04780 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SHEARER CHARLENE ET AL
VS
SHERATON VALLEY FORGE HOTEL ET
R. Thomas Kline
.00
16.00
08/28/2001
IRWIN MCKNIGHT & HUGHES
duly sworn according to law,-says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
RADISSON VALLEY FORGE HOTEL
but was unable to locate Them in his bailiwick. He therefore
deputized the sheriff of MONTGOMERY
serve the within WRIT OF SUMMONS
County, Pennsylvania, to
On August 28th 2001 this office was in receipt of the
attached return from MONTGOMERY
Sheriff's Costs:
Docketing
Out of County
Surcharge
Sworn and subscribed to before me
this ~ day of ,•
~~~ A.D.
~ e ProthonotaryT~
Sheriff or Deputy Sheriff who being
So answe
6.00
. 0 0 ~.~~
10.00 R.`"Thomas Kline
.00 Sheriff of Cumberland County
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2001-04780 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SHEARER CHARLENE ET AL
VS
SHERATON VALLEY FORGE HOTEL ET
R. Thomas Kline Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
GF MANAGEMENT A LIMITED PARTNERSHIP
to wit:
but was unable to locate Them in his bailiwick. He therefore
deputized the sheriff of MONTGOMERY County, Pennsylvania, to
serve the within WRIT OF SUMMONS
On August 28th 2001 this office was in receipt of the
attached return from MONTGOMERY
Sheriff's Costs: So answer ,/
Docketing 6.00
Out of County .00 ~r
Surcharge 10.00 R.R. h~Kline
.00 Sheriff of Cumberland County
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08/28/2001
IRWIN MCKNIGHT & HUGHES
Sworn and subscribed to before me
this ~ day of
a2.ot~ i A . D .
~~ ~ h
a /C ~ i s~,c`~h
Ih The Court of CO~nmOn Pleas of Cumberland County, Pennsylvania
~t~arlene M. Shearer, et. al. ` .~ ,,
VS. A ,~
Sheratoq Valley Forge Hotel, et. a c~0\
Serve:
"~D~~~Sheraton Valley rbrge Hot 01-4780 Civil
K~NS of ?c'ass~y .~~ 19~0l•
Now, 8/14/01 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Mohtgomexy County to execute this Writ, this
deputation being made at th e „ ; sk of the Plaintiff.
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LAST DAYFOR SERVEC,E ~.,_.,..,_.,:
~~. .d°
Sheriff of Cumberland County, PA
Af~ida~at ®f Sere~ace
Now, ~~%~ ` G,,, ,' ~ ~,~,,,,~ , 20 u ~ , at p~r/J~ o'clock _~ M. served the
(7-_
within s~/~o v-~-
upon ~~1i2(~~rC2-~o
at ~/~,~ ~ v-~-
by handing to
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u7.P -l C.
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a , ~~J~-~„ copy of the original j~~t ~ ~;~
~ an -~
and made 1nioVm to ~~/~~^'~- co l~t~therleo
So answer , ~/ 1 -\
~~---- ` _ `~'s y
9 „o ~r ~..~ r, i - ~ -
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~ 'heri' o ~Jd,.,,,,,/ County,~PA `
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Sworn and subscribed before
me this ~~ d~a of , 20~
` `OCSv~^'VW
COSTS
SERVICE
MILEAGE _
AFFIDAVIT
~kaS~
"N-
Tea T'he ~~aart ~f C~>c>r-®n Pleas ®f ~naberlanal C®~anly9 Pennsylvania
Charlene M. Shearer, et. al.
VS. ~ '
Sheraton Valley Forge Hotel, et. al. \u~
Serve:
Raddisson Valley Forge Hot~D. 01-4780 Civil
~I60'~~rct ~vG
K~NR aF~ussil, r~ l9`~01•
Now, 8/14/01 , I, SHERIFF OF CT.TIVIBERLANI> COUNTY, PA, do
hereby deputize the Sheriff of Montgomery County to execute this Writ, this
deputation being made at the u k of the Plaintiff.
LAST DAY FOR SERVICE _ ~,--. ~'' ~'~
~ ~'
Sheriff of Cumberland County, PA
Affaavit ®~° Service
Now, g~~~= ~~/~~~,,,~ ~ , 20 ~ / , at ~~~ o'clock ~ M. served the
~' ~' /
within
upon /~[ ~dtA- ~~-c/~G/
at /7'/,/S~ ~-~
by handing to
0
a ~~.~_ copy of the original G.i~ ' - ~=~"` --
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and anade ta:own to ,/~~a-v ~, the contents thereof ,~~'~',
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So answers, ,4') an
C/.~J.•~
__..__,_.-_..._._. _«v.~-~~_.,.r ~7
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" - _ J J heriff of ~ County, PA
COSTS
Sworn and subscribe before SEP~VICE $
me this ~ da of , 20~ ~ MILEAGE
~y~q AFFIDAVIT
- ~a~~ $
..
I~ The ~®urt ~#` C®naa~®n Plus ®f Ca~anta~rland County, P~nrisy~~anaa
Charlene M. Shearer, et. al.
' VS. \~
Sheraton Valley Forge Hotel, ~. al. ,~
Serve: `GF Management No. 01-4780 Civil ~
~~(pp '~~rt'r O~UG
~,~ of?rNSS~i,'?s 15~f~v
Now, s/14/ol , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Montganery County to execute this Writ, this
deputation being made at th ~1~~~L~k of the Plaintiff.
.~°~ ~
LAST DAYFOR SERVICE h - ~
Sheriff of Cumberland County, PA
Ag~davit ®f ScrsTicc
Now,~~~~„ ~ ~ „ ~,~ , 20_ ,~_, at oyyj-" o'clock _~ M. served the
within f~v v-c
upon ~~i>2~~]?~ ~ I oe~ ~'/~ s.~
at~~~v-`
by handing to ~ ~`
a ~~ copy of the original ws2,-r-' °~
a ~r ~.
~:-_
and made knor~rn to ~~,,,~__ the contents~~re~, ~--~;
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'~ ~"' ~ /. 1 ~ T4~ t
SO anSWeTS, ~/IL
W ~C
` ~~ Tl"gherigf of County, PA
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COSTS
Sworn and subscribe before SERVICE _
me this ~ d o , 20 ~ ~ MILEAGE _
AFFIDAVIT
~~as~
DEVLIN & DEVIN
By: Ramon D. Townsend, Esquire
Attorney H)#: 50371 Attorney for Defendants
Suite 200
100 West Elm Street
Conshohocken,PA 19428
CHARLENE M. SHEARER and
MERVIN E. SHEARER, her husband
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
SHERATON VALLEY FORGE HOTEL
RADISSON VALLEY FORGE HOTEL
And CF MANAGEMENT
NO.Ol-4780
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Defendants, Sheraton Valley Forge Hotel,
Radisson Valley Forge Hotel and GF Management regarding the above-captioned matter.
DEVLIN & DEVINE
MON D. TOWNSEND, ESQUIRE
Attorney for Defendants
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DEVLIN & DEVIN
By: Ramon D. Townsend, Esquire
Attorney ID#: 50371 Attorney for Defendants
Suite 200
100 West Elm Street
Conshohocken,PA 19428
CHARLENE M. SHEARER and COURT OF COMMON PLEAS
MERVIN E. SHEARER, her husband CUMBERLAND COUNTY
vs.
SHERATON VALLEY FORGE HOTEL : NO.OI-4780
RADISSON VALLEY FORGE HOTEL
And GF MANAGEMENT
PRAECIPE FOR RULE TO FILE COMPLAINT
TO THE PROTHONOTARY:
Please enter a Rule on plaintiff in the above-entitled matter to file a Complaint within
twenty (20) days or suffer judgment of non pros.
DEVLIN & DEVINE
BY: RAMON D. TOWNSEND, ESQUIRE
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Attorney for Defendants,~~~/y2~
RULE TO FILE COMPLAINT
TO THE WITHIN PLAINTIFF:
You are hereby ruled to file a Cor•.plair!t :.~'u in tv.~enty (20; days after service hereof.
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PROTHONOTARY
3/aa f ~a~
f3~
CHARLENE M. SHEARER and : IN THE COURT OF COMMON PLEAS OF
MERVIN E. SHEARER, her husband, :CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v.
NO.Ol-4780 CIVIL TERM
CIVIL ACTION -LAW
SHERATON VALLEY FORGE HOTEL,
RADISSON VALLEY FORGE HOTEL,
and GF MANAGEMENT,
Defendants
PRAECIPE TO SETTLE AND DISCONTINUE
To Curtis R. Long, Prothonotary:
Please mark the above-captioned case settled and discontinued and issue a Settlement
Certificate to Marcus A. McKnight, III, Esquire, at 60 West Pomfret Street, Carlisle,
Pennsylvania 17013.
Respectfully submitted,
IRWIN, McKNI~IT & HUGHES
By:
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717)249-2353
Date: June 3, 2002
i
CHARLENE M. SHEARER and : IN THE COURT OF COMMON PLEAS OF
MERVIN E. SHEARER, her husband, :CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
NO.Ol-4780 CIVIL TERM
v.
CIVIL ACTION -LAW
SHERATON VALLEY FORGE HOTEL,:
RADISSON VALLEY FORGE HOTEL,
and GF MANAGEMENT,
Defendants
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Praecipe to
Settle and Discontinue was served upon the following by depositing a true and correct copy of
the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the
date referenced below and addressed as follows:
Ramon D. Townsend, Esquire
DEVLIN & DEVINE
100 West Elm Street, Ste. 200
Conshohocken, PA 19428
IRWIN, McKN~GHT & HUGHES
By: Marcus A.~1VIcI{night, II
60 West Pomfret Street
Cazlisle, PA 17013
(717)249-2353
Supreme Court I.D. No. 25476
Date: June 4, 2002
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